International Commercial Tax

International Commercial Tax, 2nd edition takes account of the substantial developments of the last decade. With more than sixty percent new material, the book considers the outcomes of the OECD's BEPS project and the substantial consequential 2017 revisions of the OECD and UN Model tax treaties. With the continuing rise in the economic importance of non-OECD countries and the UK distancing itself from the EU, there has been a refocusing with less direct attention on UK domestic law and greater focus on the approaches of other significant countries, especially other common law jurisdictions. This provides greater flexibility as to how a particular point or issue is illustrated with practical examples. Greater attention is given to the UN Model, which is increasingly important. The book continues to compare the approach under model tax treaties with EU law and is updated with copious references and illustrations from the burgeoning jurisprudence of the EU Court.

Introduction; 1. Fundamentals and sources of international tax law; 2. The jurisdiction to tax; 3. Source country taxation; 4. Residence country taxation; 5. The limited scope of treaties; 6. Changes of source and residence; 7. Bilateral administrative issues.

Peter Harris is Professor of Tax Law at the University of Cambridge. He is the author of five international tax books and has advised for the IMF for over 20 years, assisting more than a dozen countries in drafting and reforming tax law and tax treaty policy. Harris also serves as a consultant to the DESA of the UN, contributing two chapters to its Handbook on Protecting the Tax Base of Developing Countries.